EU consultation
124 submissions from 121 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 282 submissions on this file. Shown here: the 124 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
94 submissions from industry — companies and their trade associations — against 15 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 6.3 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 5 Mar 2026 — it ran from 11 Dec 2025.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Report.
124 positions · showing 25
· · filed 5 Mar 2026 · source
Cosmetics and hygiene industry, representing Danish manufacturers of disinfectants, welcomes the opportunity to comment on the ongoing Call for evidence regarding the evaluation of the BPR. The purpose of the BPR is to ensure a high level of protection of both human and animal health and the environment in addition to improving the functioning of the internal market.
Filed in Danish · English published by the European Commission
· · filed 5 Mar 2026 · source
The following points should be discussed to simplify the BPR, while aiming to reduce the growing inequality between active substancesa result of delays in the Review Program and the introduction of new regulatory requirements: (1) Require MSCA to prioritize the assessment of Active Substance (AS) dossiers that have never been evaluated.
Consultation Response Evaluation of the Biocidal Products Regulation (BPR) 1 Introduction Sagentia Regulatory, formerly TSG Consulting, has been actively involved in the implementation of the EU Biocidal Products Regulation (BPR) since its introduction.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
THOR is a global producer of speciality chemicals, delivering high-performance biocide, flame-retardant and personal-care solutions. Founded in England, we operate world-wide, enhancing the safety, durability and functionality of products across construction, coatings, hygiene, automotive, water treatment, personal care, textile sectors and more.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 5 Mar 2026 · source
The presence of non-compliant biocidal products on the EU market raises significant concerns in terms of public health, environmental protection and the integrity of the regulatory framework established by the Biocidal Products Regulation (BPR). The BPR aims to ensure that biocidal products placed on the EU market meet strict safety, efficacy and risk assessment requirements.
Filed in French · English published by the European Commission
· · filed 5 Mar 2026 · source
Our proposal to simplify the BPR: – A single dossier only per biocidal Active Substance, regardless of the number of intended product types (pts) to be supported – Composition of such dossier: Only Part A is required (meeting the requirements of Annex II of the BPR). – Uniform application: The same rule applies to both new active substances and existing ones (under the Review Programme).
Filed in French · English published by the European Commission
European controlled environment agriculture (CEA) is among the most advanced and resource-efficient horticultural production systems in the world. High-tech CEA allows growers to grow fruits, vegetables, flowers, and plants with efficient use of water, nutrients, and energy, while minimising emissions to the environment.
· · filed 5 Mar 2026 · source
Women Engage for a Common Future (WECF) welcomes the opportunity to contribute to the evaluation of the Biocidal Products Regulation (BPR). Biocidal products are designed to control harmful organisms and therefore inherently pose risks to human health and the environment.
We would like to thank EC for the opportunity to voice our company concerns and the opportunity to contribute to the call for evidence on the BPR. As mentioned in the introduction to this consultation, biocidal products (biocides) have the important role to help to control unwanted organisms that are harmful to human or animal health or to the environment, or that cause damage to materials or human activities.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Our company has been operating under the Biocidal Products Directive and now the BPR. While we fully support the objectives of protecting human/animal health, the environment and the internal market, our operational experience shows that the current regulatory framework is no longer sustainable for organisations nor for users, including professionals, who depend on these products.
Europäische Kommission Generaldirektion Gesundheit und Lebensmittelsicherheit (SANTE) Referat E4 – Pestizide und Biozide Frau [name removed] – per Mail – Regelwerk und Beratung Ansprechpartner: [name removed] Telefon: [phone removed] [email removed] www.dgfdb.de 29.11.2022 Verordnung über Biozidprodukte – Bewertung Sehr geehrte Frau Bitterhof, sehr geehrte Damen und Herren, die Deutsche Gesellschaft für das…
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Statement for the consultation on evaluation of the EU Biocidal Products Regulation (BPR). Wood preservative manufacturer Rütgers Organics GmbH appreciates the opportunity to contribute to the process of refinement of the EU regulation No. 528/2012 (BPR).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
IT COMMENTS ON THE REVISION OF EU BIOCIDAL PRODUCTS REGULATION NO. 528/2012 Ar cle 5 Exclusion criteria Ar cle 5 should be updated taking into account the new CLP hazard classes with harmonised classifica on. EXPLANATION For ac ve substances that already have a CLP harmonised classifica on, their hazard does not need to be reassessed.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Contribution Eurodom à l’évaluation sur le règlement biocides 528/2012 Nous proposons d’introduire (dans le règlement 528/2012, ses actes d’exécution et/ou les lignes directrices d’application) une clarification et une voie d’autorisation permettant, à titre strictement encadré, l’utilisation de rodenticides biocides en milieux agricoles lorsque les finalités relèvent de la santé publique (prévention d’une zoonose)…
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Contribution to the Evaluation of the Biocidal Products Regulation (EU) No 528/2012 I-Tech AB (“I-Tech”) is a Swedish biotechnology company specialising in marine antifouling solutions. A long-time recipient of EU funding, I-Tech is the developer of Selektope® (medetomidine), an innovative biocidal active substance currently approved under the BPR.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
WTR is a SME and a relative newcomer to the BPR. While the BPR has successfully established a high level of protection for human health and the environment, its implementation has inadvertently created a regulatory environment where "data protection" is frequently used as a tool for "market protection".
Autocuidado de la Salud Ref. Ares(2026)2451026 - 05/03/2026 anefp contributions to the Public Consultation on Regulation (EU) 528/2012 concerning the making available on the market and use of biocidal products anefp welcomes the ongoing revision of Regulation (EU) No 528/2012 concerning the making available on the market and use of biocidal products (BPR) and considers it a valuable opportunity to incorporate into…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Platform Biociden, the Dutch trade association representing the biocides value chain, welcomes the European Commissions evaluation of the Biocidal Products Regulation (BPR). We believe that its current implementation is no longer fit for purpose in terms of competitiveness, predictability and proportionality and requires evaluation and reform.
Ares(2026)2450779 CWAW Policy Briefing: Wild AnimalRef. Welfare in the BPR - 05/03/2026 Wild Animal Welfare in the Biocidal Products Regulation Evidence submitted to the Biocidal Products Regulation evaluation, March 2026 The Center for Wild Animal Welfare (CWAW) is a non-profit organisation that aims to improve the lives of wild animals through government policy.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
PAN Europe welcomes the opportunity to contribute to the evaluation of the Biocidal Products Regulation (BPR) and emphasises the importance of a strong, science-based framework to protect human health, animals, and the environment. Biocidal products are inherently hazardous, and their use requires high regulatory standards to ensure safety. However, significant challenges remain in the implementation of the BPR.
Ares(2026)2450053 - 05/03/2026 Biocidal products regulation evaluation - 05 Ref. March 2023 “The purpose of this Regulation is to improve the free movement of biocidal products within the Union while ensuring a high level of protection of both human and animal health and the environment. Particular attention should be paid to the protection of vulnerable groups, such as pregnant women and children.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Our company is an SME that has supported an active substance under the BPD and continues to do so under the BPR. We believe the aims of the BPR are still relevant but that there have been, and continue to be, areas where significant improvements could be made to the cost effectiveness and efficiency by ensuring greater clarity, restricting ad hoc changes and ensuring that robust data underpins any alterations.
Alliance to Save Our Antibiotics feedback on Biocides Products Regulation, March 2025 The Alliance to Save Our Antibiotics believes that much tighter regulation of biocide use is needed in the EU, to minimise the contribution that these chemicals make to the rise of antimicrobial resistance (AMR).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Pesticide Action Network (PAN) Germany welcomes the opportunity to comment on the Regulation on Biocidal Products Regulation (EU) No 528/2012 (BPR) and its evaluation. From an environmental and consumer protection perspective, the BPR is a very important and useful legal instrument for establishing uniform provisions to regulate the placing on the market and use of biocidal products and biocidal treated articles…
Non-compliant biocidal products put EU consumers health at risk.The BPR ensures that biocidal products placed on the EU market meet stringent safety and efficacy standards, minimizing risks to human health and the environment: Non-compliant products circumvent regulatory scrutiny, posing potential health hazards due to unknown toxicity, inadequate risk assessments, and misleading safety claims.
VVVF and VLK, the Dutch Association of Paint and Printing Inks and the Dutch association of Adhesives and Sealants, welcome the opportunity to contribute to the evaluation of the Biocidal Products Regulation (BPR). In its current form, the BPR is overly complex and not fit for purpose for the paints, printing inks, adhesive and sealant industry. See the attached document for our main recommendations
· · filed 5 Mar 2026 · source
Response from Corteva to the Call for Evidence in the Evaluation of the Biocide Production Regulation (BPR) While Regulation (EU) No 528/2012 (BPR) has established a robust framework to ensure a high level of protection for human health and the environment, practical experience has revealed a number of implementation challenges that reduce efficiency, predictability, and coherence, particularly in the interaction…
EURATEX, the European Apparel and Textile Confederation, represents the interests of the European textile and clothing industry along the entire value chain from fibre producers and textile manufacturers to apparel companies and technical textile producers.
· · filed 5 Mar 2026 · source
Yordas GmbH (on behalf of an Art. 93 active substance supporter) welcomes the opportunity to contribute to this call to evidence on the EU BPR. Specifically, we would like to raise a concern regarding in situ devices, capable of generating free radicals from water or air. We believe that the legislation and particularly the guidance in its current form is not fit for purpose in relation to these devices.
· · filed 5 Mar 2026 · source
Iodine Environmental classification randomly made 10x worse under biocides in despite the scientific evidence. Iodine Endocrine Disruption emphasis on a hazard based system and ignoring rational requests for a risk based system. Forcing testing for Phys-chem properties when waivers are suitable eg.
Regulation (EU) No 528/2012 (BPR) harmonised procedures, improved traceability and strengthened the formalisation of scientific requirements for active substances (AS) and products. However, the current functioning of the scheme has significant structural limitations.
Filed in French · English published by the European Commission
· · filed 5 Mar 2026 · source
We recently received a request from our eCA regarding an active substance that has been under submitted under the BPD. The authority is now asking to add developmental neurotoxicity (DNT) to the core dataset, specifically requiring that this endpoint be covered within an Extended One Generation Reproductive Toxicity Study (EOGRTS).
UEIL (the Union of the European Lubricants Industry) represents the interests of the lubricants industry in Europe, with a special focus on SMEs and independent companies that produce lubricants and metal processing fluids essential for the automotive and industrial sectors.
· · filed 5 Mar 2026 · source
Belgian Competent Authority for Biocides Position Paper for the European Commission Call for Evidence - REFIT of the Biocidal Products Regulation (BPR) INTRODUCTION Belgium welcomes the opportunity to contribute to the European Commission’s Call for Evidence in the context of the REFIT evaluation of Regulation (EU) No 528/2012 (BPR).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 5 Mar 2026 · source
Peroxygens, a Cefic sector group, represents the European producers of hydrogen peroxide, we welcome the European Commissions evaluation of the Biocidal Products Regulation and the opportunity to contribute to this exercise, which assesses the Regulations fitness for purpose after more than a decade of implementation, in line with the Better Regulation Guidelines.
The Polish Association of Cosmetic and Detergent Industry (PSPKD), representing manufacturers of cosmetics, cleaning products and biocidal products, considers the evaluation of the Biocidal Products Regulation to be an important moment to carry out a comprehensive revision of the Biocidal Products Regulation so that it effectively achieves its original objectives: protecting public health, ensuring a high level of…
Filed in Polish · English published by the European Commission
The Finnish Cosmetic and Hygiene Industry Association (Kosmetiikka- ja hygieniateollisuus ry) is pleased to share some observations in this Call for Evidence on the Biocidal Products Regulation (BPR). While recognizing the objectives of BPR, our experience shows the current system is overly complex, slow, and administratively challenging for both businesses and authorities.
· · filed 5 Mar 2026 · source
The Chemical Industry Federation Finland supports the revision of the BPR. The availability of biocidal active substances and market for new biocidal solutions in EU is diminishing due to the strict interpretation of exclusion criteria, high uncertainty in getting approval, disproportionately high costs and long time-to-market.
Biocides for Europe, a sector group of Cefic, would like to take this opportunity to present our 4-point action plan to simplify the BPR. The document outlines key actions and enablers to enhance the EUs competitiveness, improve time to market, remove uncertainty, and strengthen the innovation framework. The document draws on the experience of the Biocides for Europe membership and reflects our initial findings.
Czech Republic's Submission in Response to the Call for Evidence – BPR Evaluation The concept of Biocidal Product Family (BPF) may be either cancelled or simplified. The original idea behind the BPF concept was to group together products that are essentially identical, carry the same level of risk, and whose changes in composition wouldn’t affect their effectiveness.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Detic is the Belgian and Luxembourg association for producers and distributors of cosmetics, cleaning and maintenance products, adhesives, sealants, biocides and aerosols. We call for a trageted revision of the BPR that enhances regulatory efficiency and agility while preserving high standards of safety and efficacy.
· · filed 5 Mar 2026 · source
Biocidal products are used to control unwanted organisms that harm human or animal health or the environment, or that cause damage to human activities. The Regulation: to improve the functioning of the internal market for these products to ensure a high level of protection of human health, animal health and the environment.
Filed in Italian · English published by the European Commission
Evaluation of the BPR – Impact on PT 8 Wood Preservatives Position of an SME Manufacturer 1. Introduction This statement is submitted from the perspective of an European SME manufacturer of wood preservatives. Kurt Obermeier GmbH is located in an economically disadvantaged region of Germany and employs approximately 180 people.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The full and faithful implementation of the BPR is essential for the proper functioning of the single market in the maritime manufacturing industry, which is critical for the sectors competitiveness. The purpose of the attached position paper is to outline the status of the European product registration process for Biocidal Products and its implications for the global maritime industry, as well as the challenges the…
Feedback from UMCO GmbH to the Call for evidence and public consultation for the evaluation of the Biocidal product regulation The scope of the BPR is designed to protect humans, animals, and the environment, and its intention remains fundamentally justified, having significantly enhanced protection for these organisms. However, there are certain aspects of the regulation that warrant re-evaluation.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Confederation of Danish Industry share the Commissions view that the current BPR framework presents substantial regulatory and practical challenges. We are ready to contribute to identifying and implementing constructive solutions to improve the system, and our members are committed to ensuring high standards to protect the environment.
BPR Evaluation: call for evidence / public consultation: CEPA position paper CEPA welcomes the opportunity to contribute to the evaluation of the Biocidal Products Regulation (BPR) and has consistently supported the objectives the Regulation pursues in terms of protecting human health and the environment.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 5 Mar 2026 · source
Biocidal products are designed to kill or limit pests and unwanted microorganisms, meaning their function inherently involves harming living organisms. Although we recognise the benefits for public health and the protection of materials, their release into the environment and the resulting exposure of non-target organisms - including humans - cannot be fully avoided.
Essity is a leading global hygiene and health company touching the lives of 1 billion people every day. Europe is one of our primary markets for developing, producing, and distributing our products such as tissue paper products, absorbent hygiene products e.g. incontinence products, menstrual products, baby diapers as well as wound care products and other medical solutions.
Federchimica response to the call for evidence for the Biocidal Products Regulation evaluation Federchimica is the abbreviated name of the Italian Federation of the chemical industry. At the present time 1500 companies, with a total of 90.000 employees, are part of Federchimica. They are grouped into 17 Associations, articulated into 38 product groups.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
As a glocal manufacturer of naturally derived ingredients for various sectors, we welcome the opportunity to give feedback on the BPR in its current form. Please see attached document detailing our observations and suggestions for improvement. Thank you.
PETA Science Consortium International e.V. ('the Science Consortium') is grateful for the opportunity to comment on the call for evidence for an evaluation of the Biocidal Products Regulation (BPR). The evaluation provides a pivotal opportunity to determine if the current implementation of the Regulation aligns with the EUs commitment to phasing out animal testing for chemical safety assessments.
· · filed 5 Mar 2026 · source
High cost of investment, long and unpredictable timelines to deliver new chemical solutions to the EU market, and uncertainity around regulatory outcomes means companies are increasingly unlikely to support new chemical solutions through the BPR process.
The revision of the Biocidal Products Regulation is an opportunity to address fundamental weaknesses of the current system and to make procedures reliable again. For manufacturers of washing, care and cleaning products, it is particularly important to reduce duplicative regulations and unnecessary administrative burdens to ensure predictability and stable supply.
Filed in German · English published by the European Commission
· · filed 5 Mar 2026 · source
Delays and non-compliance with regulatory timelines: MSCA often respond slowly or fail to meet BPR timelines. For example, attempts to contact a MSCA via ECHA channels were unsuccessful. Two communications via R4BP 3 (NMP-C-1879542-87-00/F, Dec 2025; NMP-C-1885510-02-00/F, Jan 2026) showed no indication of being read until 17/02/2026.
The Danish Coatings and Adhesives Association (DFL) would like to thank for the opportunity to contribute to the ongoing evaluation of the EU Biocidal Products Regulation (BPR). Biocides and biocidal products play a key role for both our industry and its customers. DFL therefore supports a thorough revision of the Biocidal Products Regulation. Please see the attached document with our comments.
The Biocidal Products Regulation serves to protect people, nature and the environment by subjecting biocidal products to strict authorisation and active substance testing. However, this also leads to considerable regulatory restrictions and costs for companies.
· · filed 5 Mar 2026 · source
BPCA is the UKs not-for-profit membership organisation for the professional pest management sector. We represent over 700 companies and individuals, ranging from family-run businesses to multinational service providers. Our members include pest management businesses that use biocidal products for public health pest control across the UK (including N.
· · filed 5 Mar 2026 · source
ADELMA is a business organisation that brings together companies that manufacture and market detergents and cleaning and maintenance products, pesticides and biocides, both those used in the home and those used in institutional, professional and industrial applications.
LANXESS appreciates the possibility of contributing to the process of refinement of the EU regulation No. 528/2012 (BPR). Although we consider it an extremely important and irreplaceable piece of European legislation, we would like to provide our position aiming at improving the operability, harmonization and fair implementation of the BPR.
· · filed 5 Mar 2026 · source
textil+mode (t+m), representing the German textile and fashion industry, welcomes the opportunity to contribute to the evaluation of the Biocidal Products Regulation (BPR). While supporting the BPRs objectives, we highlight key challenges for textile downstream users regarding predictability and transparency of regulatory processes, availability of approved active substances for critical applications (including…
· · filed 5 Mar 2026 · source
As a company with more than 20 years of experience in the pest control sector, and within the framework of the Biocidal Products Regulation (BPR), we would like to highlight the following negative aspects related to its implementation, as well as the impact observed over the years since its entry into force: The current level of regulatory stringency applied within the European Union is leading to a progressive and…
EUsalt welcomes the Commissions initiative to evaluate the Biocidal Products Regulation (BPR) to assess its fitness for purpose. As an association representing salt producers, we have been engaged in the BPR process for a significant amount of time.
· · filed 5 Mar 2026 · source
Association of Chemical Industries Dimičeva 13, 1504 Ljubljana, Slovenia, [phone removed], [email removed] 1. Ref. Ares(2026)2422419 - 05/03/2026 General A targeted and comprehensive reform of the Biocidal Products Regulation (BPR) to ensure the availability of effective biocidal products is urgently needed.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Health and Environment Alliance (HEAL) welcomes the Call for Evidence on the evaluation of the Regulation (EU) No 528/2012 on biocidal products (BPR). Biocidal products have the aim of killing or controlling unwanted living organisms. They are designed to affect organisms and therefore have the potential to pose serious hazards and risks for people and the environment.
The Spanish Competent Authority for the Environmental matters of Biocides authorisation would like to acknowledge the opportunity to contribute to this Call for evidence for an evaluation of the BPR. The BPR regulation is a valuable tool that Member States have given themselves as a frame that visions the highest levels in protection of consumers and the environment and works in favor of the single European market.
The placing on the market and the use of biocidal products in the EU are regulated by the Biocidal Products Regulation (EU) No 528/2012 (BPR). Its objective is to improve the functioning of the internal market. At the same time, it aims to ensure a high level of protection for human and animal health as well as for the environment.
The objective of the BPR is to improve the functioning of the internal market by harmonising the rules on the making available on the market and use of biocidal products, while ensuring a high level of protection of both human and animal health and the environment.
Filed in German · English published by the European Commission
We welcome the opportunity to contribute to this consultation and to support the Commission in shaping a modern, balanced, and science-based BPR. Biocides are essential for protecting public health, ensuring food safety, maintaining critical infrastructure, and supporting the EUs sustainability objectives.
Response of the Finnish safety and chemicals agency (Tukes) to the Call for Evidence in the evaluation on the BPR Overall considerations The Biocidal Products Regulation (BPR) has significantly improved the harmonisation of risk assessment, approval and authorisation procedures for active substances and biocidal products across the EU.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 5 Mar 2026 · source
We support the objectives of the Biocidal Products Regulation (BPR), in particular to harmonise the internal market and to ensure a high level of protection of human health and the environment. Unfortunately, implementation is disastrous. In particular, we call for: 1. Framework conditions conducive to innovation for new active substances 2. Provisional authorisations 3.
Filed in German · English published by the European Commission
Dear European Commission, Please see the attached file for our full feedback. Broadly, we are asking you to consider three components: 1. Integrate welfare-relevant endpoints for aquatic animals. 2. Include aquaculture-specific exposure scenarios in risk assessment frameworks. 3. Evaluate the Regulations net welfare impact. Warmly, Haven King-Nobles (Executive Director, Fish Welfare Initiative)
The World Iodine Association (WIA) welcomes the opportunity to contribute to the European Commissions evaluation on the implementation of the Biocidal Products Regulation (BPR). In this context, WIA calls the European Union to recognize the essential role of iodine in human nutrition and health.
SEASALT Europe welcomes the evaluation of Regulation (EU) No 528/2012 (BPR) and submits the attached report to document the systemic failures arising from the inclusion of natural sea salt within this framework.
The Global Policy Research Group welcomes the opportunity to contribute to the evaluation of the Biocidal Products Regulation (BPR). While the Regulation has successfully harmonized the internal market, this submission highlights a significant regulatory blind spot: the welfare of the 640 million fish farmed annually in the EU.
Give your feedback on: Biocidal Products Regulation – evaluation Ref. Ares(2026)2395149 - 04/03/2026 ES Mi opinión como Responsable de Registros sobre BPR no creo que diste de la de todo el sector empresarial, problemas reales que muchas empresas señalamos constantemente dentro del marco del Reglamento de Productos Biocidas (BPR).
Filed in Spanish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The placing on the market and use of biocidal products in the EU is regulated by the Biocidal Products Regulation (EU) No 528/2012 (BPR). Its aim is to improve the functioning of the internal market. At the same time, it aims to ensure a high level of protection for human and animal health and the environment.
Filed in German · English published by the European Commission
Biocidal Products Regulation – evaluation 1. Effectiveness The purpose of the Biocidal Products Regulation (BPR) is broadly supported by our company, in particular its aim to harmonize the internal EU market and to ensure a high level of protection for human health and the environment.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Merck KGaA supports a truly harmonised EU market with clear, predictable rules that protect human health and the environment while enabling access to effective biocidal products. In our view, the current functioning of the BPR does not meet these needs.
Humane World for Animals would like to thank the European Commission for the opportunity to provide feedback on the European Union's Biocidal Product Regulation, EU BPR (Regulation (EC) 528/2012). Our organisation aims to tackle the root causes of animal cruelty and suffering to create permanent change, and advocate for a shift toward science-driven, non-animal safety assessment strategies for chemical management…
· · filed 4 Mar 2026 · source
This contribution addresses the evaluation of the BPR from the perspective of an inspector of a small national enforcement authority (NEA) in Germany. From my point of view the transitional period is much too long - more than 26 and expected more than 30 years, actually! So I would therefore very much welcome it if this period could be shortened.
formulateurs, distributeurs et/ou utilisateurs de biocides à usage industriel, professionnel et/ou privé Vereniging van fabrikanten, formuleerders, verdelers en/of gebruikers van biociden voor industrieelberoeps- en/of privégebruik Bioplus Probois Contribution to the evaluation of the Biocidal Products Regulation(BPR) 04 March 2026 Bioplus-Probois is the Belgian association of producers, formulators, and…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 4 Mar 2026 · source
For paints and varnishes, biocides are very relevant for various applications: for the preservation of water-based products, the protection of façades by film preservatives, wood preservation or antifouling. However, we note that it is becoming increasingly difficult to continue to enable these applications.
Filed in German · English published by the European Commission
· · filed 4 Mar 2026 · source
The Biocidal Products Regulation’s objective of placing effective biocidal products on a harmonised market while ensuring a high level of protection of human and animal health and the environment is essential. However, significant barriers are encountered.
Filed in Dutch · English published by the European Commission
· · filed 4 Mar 2026 · source
On behalf of The Association of Danish Wood and Furniture Industries (Træ- og Møbelindustrien TMI), we are pleased to submit our comments regarding the evaluation of the Biocidal Products Regulation (BPR). TMI is the industry association representing Danish manufacturers of wood products and furniture, with a strong focus on sustainable construction and materials.
OXYXO is a livestock biosecurity company (pigs, poultry, cattle) that has been active in France and internationally with breeders, veterinarians and sectoral professionals for more than 20 years. Our contribution relates to the use of biocides in animal husbandry (disinfectants, insecticides, rodenticides) and identifies several structural flaws in the BPR: lack of field validation of disinfectants under real-life…
Filed in French · English published by the European Commission
Please find attached the Dutch Contribution to the Public Consultation as Part of the Evaluation of the Biocidal Products Regulation. The Dutch contribution was developed through collaboration between the Board for the Authorisation of Plant Protection Products and Biocides (Ctgb), the National Institute for Public Health and the Environment (RIVM), the Human Environment and Transport Inspectorate (ILT), and the…
Placing on the market and use of biocidal products in the EU are regulated by the Biocidal Products Regulation (EU)No. 528/2012(BPR). Its aim is to improve the functioning of the internal market. At the same time, it aims to ensure a high level of protection for human and animal health and the environment. In accordance with the precautionary principle, particular attention is paid to protecting vulnerable groups.
March 2026 Ref. Ares(2026)2378268 - 04/03/2026 Evaluation of Biocidal Products Regulation EBI position paper European Boating Industry (EBI) represents the recreational boating and nautical tourism sector at European level. The building of recreational boats, yachts and components together with a strong refit and repair sector are among one of the EU’s success stories in the maritime sector.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 4 Mar 2026 · source
This contribution addresses the evaluation of the BPR from the perspective of water service operators and environmental protection, drawing on operational experience in drinking water supply and wastewater treatment and monitoring of impacts on aquatic ecosystems.
Knoell group, a global consultancy with over 20 years of experience in the biocides sector, notes the importance of this evaluation to address the key challenges identified under the BPR to ensure a good functioning of the biocides European market while protecting human health and the environment.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
AnimalhealthEurope, the association representing the manufacturers of veterinary medicines, vaccines and other animal health products welcomes the possibility to provide feedback on the evaluation of the Regulation 528/2012 on making available on the market and use of Biocidal Products (BPR).
The attached document represent the feedback which reflects the official industry position of CEPE and is fully supported by AkzoNobel. It aims to provide constructive input based on practical experience with the implementation of the BPR framework and its impact on the coatings industry. A summary of the key feedback points is provided in the attached document.
· · filed 4 Mar 2026 · source
FCIO supports a targeted and comprehensive reform of the Biocidal Products Regulation to ensure the harmonisation of the internal market and the availability of effective biocidal products in Europe. High regulatory requirements, lengthy procedures and significant uncertainties in permitting and authorisation processes place a heavy burden on businesses.
Filed in German · English published by the European Commission
Please see the attached file for NVZ's full response. The NVZ Clean | Hygienic | Sustainable (NVZ) is the Dutch trade association for manufacturers and importers of products related to cleaning, disinfecting and maintaining the home and work environment. The NVZ fully supports the objective of the BPR evaluation to simplify and reduce administrative burden for economic operators and competent authorities.
A.I.S.E., the voice of the cleaning and hygiene products industry in Europe, welcomes the opportunity to provide comments to this call for evidence on the Biocidal Products Regulation evaluation. A.I.S.E. fully supports the objective of the BPR evaluation to simplify and reduce administrative burden for economic operators and competent authorities. A.I.S.E.
The German Environment Agency is the agency responsible for environmental risk assessments of biocidal active substances and products in Germany. We welcome the initiative of the European Commission to evaluate the Biocidal Products Regulation (BPR). While the BPR undoubtedly already reduced emissions of biocidal active substances into the environment, we see room for some improvements.
CEPE, The European Council of the Paint, Printing Ink and Artists' Colours Industry, welcomes the opportunity to contribute to the call for evidence on the BPR. The EU paints and inks industry encounters significant difficulties and concerns with this very complex biocide legislation, and we believe that, in its current form, it is not fit-for-purpose. Please find attached our contribution.
In response to the call for public comments on the implementation of the Biocidal Product Regulation The following expresses the views and opinions of Necon Technologies Limited a stakeholder in the biocide industry. Effectiveness of the Regulation as it currently stands.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Stellungnahme Verordnung über Biozidprodukte – Bewertung März 2026 Vorbemerkung Die Biozidprodukteverordnung (BPR, Verordnung (EU) Nr. 528/2012) ist ein zentrales Regelwerk für den Binnenmarkt, das seit 2013 die Zulassung und Verwendung von Biozidprodukten in der EU regelt.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 3 Mar 2026 · source
As matters stand, the BPR does not require the assessment of behavioural disruption, chronic stress responses, impaired feeding, or long-term immunological compromise in the animals to which biocidal products are applied. The current data requirements set out in Annexes II and III make no explicit provision for aquatic animal welfare considerations.
This document presents practical feedback from industry stakeholders regarding the implementation of Regulation (EU) No 528/2012 concerning the making available on the market and use of biocidal products (BPR). It aims to contribute constructively to the ongoing evaluation and improvement of the European regulatory framework.
Statement of CHT Germany GmbH on the evaluation of the Biocidal Products Regulation (EU) No 528/2012 1. Introduction and basic classification CHT Germany GmbH expressly welcomes the evaluation of the Biocidal Products Regulation (BPR) announced by the European Commission in 2027 as well as the ongoing public consultation.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 3 Mar 2026 · source
A process for establishment for MRLs for all biocidal active substances potentially coming into contact with food should be included in the BPR under next amendment. Each active substance used as a biocide and not being an active substance under PPPR (Reg EU 1107/2009) or VMPR (Reg EU 2019/6) should have an established process for setting MRLs under BPR.
Règlement sur les produits biocides — Évaluation EUSurvey - Survey 2026 BPR Evaluation : call for evidence / public consultation : Swiss statement One of the major achievements of the BPR has been the establishment of a scientifically robust and transparent decision making process firmly anchored in sound risk assessment.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Regulatory Institute Response to the Call for Evidence on Biocidal Products Regulation – Evaluation www.howtoregulate.org The Regulatory Institute is pleased to submit its response to the Call for Evidence on the Biocidal Products Regulation – Evaluation. The Regulatory Institute is a non-profit think tank committed to improving regulation globally so that regulations benefit us all.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We welcome the opportunity to provide feedback on the Evaluation of Regulation (EU) No 528/2012 on biocidal products (BPR). Our input focuses on a category of products for which the current regulatory framework imposes disproportionate administrative and economic burdens: veterinary diagnostic (Dx) products that incorporate small quantities of biocidal active substances such as preservatives or stabilisers (details…
Over the past year, several attempts to identify a competent authority willing and able to take responsibility for biocidal dossiers have highlighted the extent of the capacity crisis within the current BPR system. • In September 2025, we contacted the Spanish authority to inquire whether they could act as evaluating Member State for a forthcoming renewal dossier.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Give your feedback on: Biocidal Products Regulation – evaluation Evergreen Garden Care Österreich GmbH In mid-2025, Evergreen approached several competent authorities in Central Europe to identify a receiving Member State willing to accept a submission under the simplified authorisation procedure.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
DIPARTIMENTO DELLA PROGRAMMAZIONE, DEI DISPOSITIVI MEDICI, DEL FARMACO E DELLE POLITICHE IN FAVORE DEL SERVIZIO SANITARIO NAZIONALE DIREZIONE GENERALE DEI DISPOSITIVI MEDICI E DEL FARMACO Ufficio 8 – Biocidi e cosmetici Viale Giorgio Ribotta, 5 - 00144 Roma PEC:[email removed] 4 March 2026 Response of the Italian Competent Authority to the Call for Evidence in the Evaluation of the Biocidal Product Regulation (BPR)…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Regulation (EU) No 528/2012 (BPR) constitutes a necessary and valuable framework to monitor active substances and biocidal formulations placed on the European market. It ensures a high level of protection for human health and the environment and provides a harmonized system of evaluation across Member States. Biocides are, in many cases, the only available tools for protection against vector-borne diseases.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Regulation's complex requirements make it difficult for SMEs to keep existing products on the market while also investing in biocidal innovation. Responsible employer practices must include the highest standards of care and caution regarding occupational safety and health requirements, and environmental protection when biocides are used.
26 February 2026 Response of the Swedish Chemicals Agency to the Call for Evidence in the Evaluation of the Biocidal Product Regulation (BPR) General aims of the BPR and the precautionary principle The BPR recognizes that biocidal products are necessary for the control of organisms that are harmful to human or animal health and for the control of organisms that cause damage to natural or manufactured materials…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Statement by the German Agricultural Industry Association (IVA) The EU Biocidal Products Regulation (BPR) urgently needs to be revised! The German Agricultural Industry Association (IVA) represents the interests of manufacturers of biocidal products for pest control in Germany.
BPR evaluation Contribution of the DE federal biocides authorities The following provides the views and observations of the federal authorities responsible for the implementation of the BPR in Germany. The Biocidal Products Regulation (the ‘BPR’) aims to improve the functioning of the internal market through harmonising the rules for biocidal products in the Union while ensuring a high level of protection for human…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
IT COMMENTS ON THE REVISION OF EU BIOCIDAL PRODUCTS REGULATION NO. 528/2012 ARTICLE 5 Exclusion criteria TO AMEND PAR.1 AS FOLLOWS: […] (a) active substances which have been classified in accordance with Regulation (EC) No 1272/2008 as carcinogen category 1A or 1B; (b) active substances which have been classified in accordance with Regulation (EC) No 1272/2008 as mutagen category 1A or 1B; (c) active substances…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 23 Feb 2026 · source
The objectives of the Biocidal Products Regulation (BPR) are widely supported, particularly the harmonisation of the internal market and the assurance of a high level of protection for human health and the environment. However, the practical implementation of the Regulation is not functioning as intended. 1. Systematic Non-compliance with Legal Timelines.
· · filed 20 Feb 2026 · source
We acknowledge the importance of BPR objectives but see major structural issues preventing the Regulation from functioning effectively. Below, we critically assess key challenges and propose improvements. 1. Fragmented Internal Market Due to Transitional Period Rules Despite its harmonisation goal, the internal market is still highly fragmented because Member States retain heterogeneous rules for products in the…
1. Knelpunten BPR met Arbowet en Besluit GGO (Desinfectie-eisen) 1.1 Stapeling van regelgeving Onderzoekers in laboratoria krijgen te maken met drie regimes: BPR (markttoelating), Arbowet (EU 2000/54, werknemersbescherming) en Besluit GGO (milieucontainment). Een biocide dat onder BPR is toegelaten voldoet niet automatisch aan Arbo- of GGO-eisen.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 16 Feb 2026 · source
The European Wood Preservation Association (EWPA) and the European Wood Preservative Manufacturers Group (EWPM) represent companies active in the development, manufacture and use of wood preservative solutions in Europe.
· · filed 10 Feb 2026 · source
While the BPR aims to harmonize the market, it fails to account for the unique nature of water treatment. Unlike industrial chemicals, water disinfectants (like chlorine or ozone) are used to meet strict public health mandates. Applying "one-size-fits-all" biocidal rules to drinking and pool waterwhich are already strictly regulated by other directivescreates redundant and "grave" administrative burdens.
The BPR regulation does not hold its promises at all. This is mainly due to the evaluation delays and market approach. Some active substances are in transition period since 10 years or more. This leads to very serious competition issues, monopoly situations, with no effect at all concerning the protection of the environment.
Aquatic Life Institute notes the relevance of this evaluation to emerging One Health and marine governance priorities. The Regulations original objectives focused on internal market functioning and protection of human and animal health and the environment.
· · filed 11 Dec 2025 · source
The existing Regulation has failed in every respect. It has not improved but worsened the ‘functioning of the biocidal products market’. 13 years after its entry into force, it has not even achieved its ‘protection objective’, since not even around 50 % of the active substance/PA combinations have been assessed at all.
Filed in German · English published by the European Commission
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